Order Code RL33430 CRS Report for Congress Received through the CRS Web The Safety of Air Ambulances May 23, 2006 Bart Elias Specialist in Aviation Safety, Security, and Technology Resources, Science, and Industry Division Congressional Research Service ˜ The Library of Congress The Safety of Air Ambulances Summary The estimated rate of air ambulance accidents has been steadily rising since the early 1990s, and has increased at a rapid rate since 1998 when the industry began to expand more rapidly and shift toward a model of more independent private air ambulance services that cover larger geographic areas. Statistics indicate that the large majority of air ambulance accidents are attributable to operational factors related to pilot situation awareness and decision making when faced with adverse environmental conditions such as darkness, deteriorating weather, rugged terrain, or some combination of these factors. Initiatives to improve air ambulance safety to date have consequently focused on additional pilot training, implementing risk management practices to improve the safety of flight operations, and using various technologies to improve pilot situation awareness in restricted visibility conditions. However, implementation of these safety measures has strictly been voluntary. The National Transporation Safety Board (NTSB) and other aviation safety experts are advocating the mandatory use of formal flight dispatch procedures and risk management practices among air ambulance operators as well as mandatory installation of terrain warning systems on air ambulance aircraft. The NTSB also found that many air ambulance accidents occur when patients are not on board, such as en route to an accident scene. Present regulations allow air ambulances to operate under a less stringent set of rules with regards to weather minimums and pilot duty times when not carrying patients. However, the NTSB believes that air ambulance flights should operate under more stringent commercial operating rules at all times that medical personnel are carried on board. Although maintenance issues have been identified in about 20 percent of all air ambulance accidents, neither the Federal Aviation Administration (FAA) nor the NTSB has placed any specific emphasis on oversight of operators or repair stations that maintain air ambulance aircraft. The present emphasis on air ambulance safety has, instead, been dominated by concerns over flight crew performance and weather-related factors. A variety of options are available to improve safety among air ambulance operators. These options include intensified oversight of air ambulance operators and regulatory changes to bring all phases of air ambulance operations under the same set of operational rules regarding weather minimums and pilot duty times; possible regulatory changes to provide for sharing and analysis of safety-related data and observations with some degree of impunity; possible aircraft design considerations to improve crash survivability; expanded application of system safety and formal risk management principles to mission planning and flight operations; enhanced training for both pilots and support personnel and operational procedures to improve coordination and situation awareness among the entire air ambulance crew and ground support team; and the use of various technologies to improve pilot situation awareness and augment pilot vision in low visibility conditions. This report will not be updated. Contents An Analysis of Air Ambulance Safety Data .............................1 The Role of Air Ambulances .........................................5 State of the Air Ambulance Industry ...................................7 Causes of Air Ambulance Crashes.....................................9 Interaction Between Pilots and Flight Conditions ................10 Pilot Situation Awareness of Weather Conditions ...............11 Mission Pressures ........................................11 Conditions in the Flight Environment .........................13 Mechanical Failures and Maintenance Related Crashes ...........14 Options for Improving Safety .......................................14 Regulatory Standards and Oversight ..............................14 Conducting Special Emphasis Inspections .....................15 Applying Consistent Regulatory Requirements During All Phases of Operation ...........................................16 Addressing Concerns Over Pilot Fatigue .......................16 Increasing Maintenance Oversight ............................18 Improving Aircraft Crashworthiness ..........................18 Implementing System Safety and Risk Management Principles .........19 Training and Procedures for Flight and Medical Crews ...............20 Technology to Improve Safety in Low Visibility Conditions ..........22 Terrain Warning Systems ...................................23 Technologies to Enhance In-Flight Visibility ...................23 List of Figures Figure 1. Three-Year Moving Average of Estimated Overall and Fatal Accident Rates for Helicopter Air Ambulance Operations ......................3 Figure 2. Factors in Helicopter Air Ambulance Accidents (1991 -2004) .................................................10 The Safety of Air Ambulances Air ambulances that conduct emergency medical service operations and other medical-related transport services include both helicopter emergency medical services (HEMS) that primarily conduct scene response transport of trauma patients and fixed-wing aircraft operations that primarily conduct inter-facility transports of critical care patients. The air ambulance industry has grown significantly over the past 25 years and is widely regarded as having a beneficial effect on improving the chances of survival and recovery for trauma victims and other critical patients, especially in rural areas. However, during this time, the air ambulance industry has been the focus of two in-depth National Transporation Safety Board (NTSB) special safety studies and numerous other investigations by aviation safety researchers that have pointed to continued concerns over the safety of its flight operations, particularly among helicopter air ambulance operators. Although the air ambulance industry and Federal Aviation Administration (FAA) regulators have taken some positive steps to address continued concerns over operational safety, the NTSB and some other aviation safety experts have voiced concerns that not enough has been done to reduce the risk of accidents in air ambulance operations. This report analyzes available air ambulance safety data, examines the current state of the air ambulance industry and factors that may influence safety within the industry, assesses causal factors underlying the recent spate of air ambulance crashes, and discusses some available options for improving safety. An Analysis of Air Ambulance Safety Data A recent increase in the number of crashes involving air ambulances has raised concerns among aviation safety experts. According to a National Transportation Safety Board (NTSB) special study focusing on aviation emergency medical operations released in January 2006, 55 crashes involving air ambulances occurred in the United States between January 2002 and January 2005.1 The NTSB noted that this number of crashes has not been seen since the 1980s. Given that the current air ambulance fleet is estimated to consist of about 750 helicopters and 150 fixed wing aircraft,2 each year over the past three years, about one in every 50 helicopter air ambulances has been involved in a crash. An article in USA Today offered the following stark analogy: “If commercial airlines lost the same proportion of large 1 National Transportation Safety Board, Special Investigation Report on Emergency Medical Service Operations. NTSB/SIR-06/01. 2 Foundation for Air-Medical Research & Education (FARE), Air Medicine: Accessing the Future of Health Care, Alexandria, VA: FARE, 2006. CRS-2 passenger jets as air ambulance companies lost helicopters, 90 airliners would crash each year.”3 Because there is no centralized database of flight records for the air ambulance industry, no one knows for sure if safety is eroding or if this increase in accidents can be explained by the large growth in the use of helicopters and airplanes for medical evacuation and patient transport. The NTSB notes that while industry estimates suggest that the number of hours flown by air ambulances has increased by about 85% over the past 15 years, the estimated accident rate for helicopter air ambulances has also risen from 3.52 accidents per 100,000 flight hours between 1992 and 2001 to 4.56 accidents per 100,000 flight hours between 1997 and 2001.4 The NTSB, however, did not provide its own estimates of accident rates or more recent figures on the annual accident rates for air ambulances. Available accident statistics and analyses reviewed by CRS have focused on helicopter air ambulance operations, which make up more than 80% of the air ambulance fleet. Consequently this report concentrates on safety data and finding related to helicopter air ambulances, although many of the issues and observations may be more broadly applicable to both helicopter and fixed-wing air ambulances. While much of the flight hour data to substantiate accident rate statistics for air ambulance operations remains sketchy, CRS analyzed helicopter air ambulance safety data and computed accident rates using accidents between 1991 and 2004 identified in the 2006 NTSB special study report, and accident data and industry estimates of hours flown by helicopter air ambulance operators cited in a comprehensive safety review and risk analysis of air ambulance accidents published by the Air Medical Physician Association (AMPA).5 This analysis estimated that the overall accident rate among air ambulance operators from 1991 to 2004 to be 3.50 accidents per 100,000 flight hours and the fatal accident rate to be 1.13 accidents per 100,000 flight hours. Looking only at the data since 1998 when a notable spike in accidents was first observed, the estimated overall accident rate rose to an average of 4.75 accidents per 100,000 flight hours and the estimated fatal accident rate increased slightly to 1.25 accidents per 100,000 flight hours. Three-year moving averages of the estimated accident rate were computed across the 14 year period 3 Alan Levin and Robert Davis, “Surge in Crashes Scars Air Ambulance Industry.” USA Today, July 18, 2005, A1. 4 Ibid. See also Ira J. Blumen, M.D., and the University of Chicago Aeromedical Safety Committee, A Safety Review and Risk Assessment in Air Medical Transport, 2002, Air Medical Physicians Association, Salt Lake City, UT. 5 CRS analysis of annual accident data and flight hour estimates provided in National Transportation Safety Board, Special Investigation Report on Emergency Medical Service Operations and Ira J. Blumen, M.D., and the University of Chicago Aeromedical Network. A Safety Review and Risk Assessment in Air Medical Transport, 2002. Note: for 2002 through 2004, CRS interpolated estimated flight hours based on industry flight hour estimates provided for previous years and an estimate of 300,000 hours flown in 2005 cited in the NTSB report. This yielded an average annual increase in flight hours between 2001 and 2004 of roughly 9.3%. CRS-3 based on available flight time estimates and are shown in Figure 1.6 The trend in the three-year moving average accident rates suggests a steady increase in the accident rate from 1991 through 2003, with a slight reversal of this trend in 2004. The data also show a slight rise in the fatal accident rate over the past five years. While these data demonstrate an increase in helicopter air ambulance accident rates, particularly since 1998, they cannot be regarded as conclusive because of the lack of reliable data on the overall number of hours flown. However, these data, based on best available information, strongly suggest that there is cause for concern regarding the safety trend for air ambulance operations. Figure 1. Three-Year Moving Average of Estimated Overall and Fatal Accident Rates for Helicopter Air Ambulance Operations 6 0 0 0 0, 5 0 1 ) s r 4 e r u P o ( e H 3 t t a h R g i 2 t l n F e d 1 i c c A 0 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 Year All Accidents Fatal Accidents Sources: CRS analysis of annual accident data and flight hour estimates provided in National Transportation Safety Board, Special Investigation Report on Emergency Medical Service Operations. NTSB/SIR-06/01 and Ira J. Blumen, M.D., and the University of Chicago Aeromedical Network. A Safety Review and Risk Assessment in Air Medical Transport, 2002, Air Medical Physicians Association, Salt Lake City, UT. Note: A three-year moving average computes the accident rate using the data from the current year and the two prior-years. There are two key concerns regarding these accident rate estimates. First, the trend shows a steady increase in estimated accident rates over the past 14 years, with 6 A three-year moving average, sometimes referred to as a three-year rolling average, is an accident rate calculation based on accidents and flight hours during the referenced year and the two prior years. So, for example, the data points for 1993 are based on accidents and flight hour estimates for 1991, 1992, and 1993. This is done to provide a more stable metric for analyzing trends among accident rates that may fluctuate significantly from year to year. CRS-4 a more marked increased since 1998. Second, these estimated accident rates are notably higher than many other commercial aviation sectors. In particular, over the same period (from 1991-2005), non-scheduled air taxi operators, which fly under the same rules as air ambulance operators carrying patients, experienced an overall accident rate of 2.52 accidents per 100,000 flight hours and a fatal accident rate of 0.67 fatal accidents per 100,000 flight hours.7 While air ambulance operations, particularly helicopter air ambulance operations, by their nature may arguably be inherently more risky than other commercial aviation operations, the relatively higher estimated accident rates coupled with the observed trend of increasing accidents and estimated accident rates suggests that the causes of these accidents and possible options to reduce these numbers is an appropriate topic for policy analysis. When the NTSB previously examined commercial emergency medical service helicopter operations in 1988, it estimated that the overall accident rate between 1980 and 1985 was 12.34 per 100,000 flight hours, almost twice the estimated accident rate experienced by non-scheduled helicopter air taxis during that period.8 Moreover, the fatal accident rate of 5.40 per 100,000 flight hour for helicopter air ambulances between 1980 and 1985 was estimated to be about 3 ½ times the fatal accident rate for non-scheduled helicopter air taxis and all turbine-powered helicopters.9 While more recent accident rate estimates among helicopter air ambulance operators have been climbing steadily, they still appear to be much lower than estimates for the early 1980s. However, the lower observed accident rates in the early 1990s suggest that safety improvements can be made in air ambulance operations to reduce the overall and fatal accident rates compared to recently observed levels. Specifically, between 1991 and 1995, the helicopter air ambulance industry had an estimated 1.81 accidents and 0.91 fatal accidents for every 100,000 flight hours, accident rates that closely resemble those of other commercial aviation operations such as the previously cited statistics for non-scheduled air taxi operators. Arguably, based on these data, the helicopter air ambulance industry has already demonstrated that it can achieve a better safety record than what it has experienced since 1998. Although air ambulance operations can be inherently riskier than other aviation operations because the environment in which they operate is more dynamic and unpredictable, some experts have raised concerns that the air ambulance industry and the FAA are simply accepting a higher accident rate than other areas of the aviation industry rather than taking steps to reduce the number of accidents.10 While the FAA and the air ambulance industry have acknowledged that ongoing safety concerns 7 Both non-scheduled air taxi operators and air ambulance operations with patients on board are conducted under Title 14 Code of Federal Regulations, Part 135. CRS calculations based on data provided in: National Transportation Safety Board, Accidents, Fatalities, and Rates, 1986 - 2005, 14 CFR Part 135, Nonscheduled Service (On-demand Air Taxis). 8 Non-scheduled helicopter air taxi are operated under Title 14 Code of Federal Regulations, Part 135 and generally do no include local air tours that are exempt from operating under this set of regulations. 9 National Transportation Safety Board, Commercial Emergency Medical Service Helicopter Operations, NTSB/SS-88/01. 10 Alan Levin and Robert Davis, “Surge in Crashes Scars Air Ambulance Industry.” CRS-5 exist, critics argue that their actions to date — largely consisting of advisory materials and recommendations requiring only voluntary compliance by operators — are inadequate. To further assess the root causes of air ambulance accidents and assess possible policy changes to improve safety in the air ambulance industry, it may be beneficial to examine the operational role of air ambulances as well as the current state of the air ambulance industry and management practices in the air ambulance industry. The Role of Air Ambulances When most people think of an air ambulance operation they are likely to first consider helicopter transports of trauma patients, such as car accident victims. This has historically been the predominant form of air ambulance service since its beginnings in the early 1970s. Large scale use of air evacuation of wounded troops was demonstrated to be an effective means of reducing combat mortality both in the Korean and Vietnam conflicts. Based on this experience, civilian air ambulance use in the United States began on a small scale starting in the early 1970s and has grown significantly since. Although some studies have found little or no benefit from helicopter evacuations of civilian trauma patients, numerous studies point to improved chances for recovery and significant reductions in mortality rates when air ambulance services are made available to trauma patients.11 Medical theory and practice holds that providing critically injured patients with surgical intervention within the first hour after injury – the so-called “Golden Hour” – can significantly improve the chances for survival and recovery.12 In practice, air ambulances, particularly helicopters, can play an important role in this intervention by providing rapid patient transport to trauma centers where they can be effectively treated, and in some cases providing advanced life support capabilities en route. The availability of this service provides an important role, especially in rural communities that lack readily accessible advanced care facilities and medical specialists. More recently, there has been increased utilization of air ambulances, both helicopters and airplanes, for both on-scene response and inter-facility transport of critical cardiac patients and stroke victims. Both helicopters and fixed-wing aircraft are also utilized for other inter-facility transfers to give patients access to specialty care facilities and medical specialists. While the on-scene response of a helicopter at a traffic accident is probably what first comes to mind when the term air ambulance is used, today about 54% of all air medical transports are from hospital to hospital, while on-scene responses make up 33%. The remaining 13% include organ and medical supply and speciality medical team transports.13 Air ambulances can also play an important role in emergency evacuation of critical care patients and 11 Association of Air Medical Services (AAMS), AAMS Brief – Part 3: Air Medical Research and What It Shows. Alexandria, VA: AAMS; National Transporation Safety Board, Commercial Emergency Medical Service Helicopter Operations; Foundation for Air- Medical Research & Education (FARE), Air Medicine: Accessing the Future of Health Care. 12 Foundation for Air-Medical Research & Education (FARE), Air Medicine. 13 Ibid. CRS-6 transport of medical supplies and staff to disaster areas, as was demonstrated in the aftermaths of Hurricanes Katrina and Rita in 2005.14 While some critics assert that air ambulance transports are being over utilized,15 there is generally widespread acceptance of the benefit provided by both the general public and the medical community. The air ambulance community acknowledges that utilization of air ambulances in some cases may, in retrospect, prove to have been unnecessary. This, they argue, is to be expected if the medical community is to assure that the maximum number of patients who could potentially benefit from air ambulance services are provided with this service. Over the past 15 years, guidelines for air medical dispatch have been refined by the air ambulance community and emergency room physicians. These various guidelines set forth circumstance-specific and patient-specific criteria for decision makers assessing whether to dispatch a flight as well as for analysts reviewing and modeling utilization and refining resource allocation across a particular geographic area.16 The industry also argues that while air ambulance services are comparatively costly when examined on a single-case basis, appropriately used air medical transport is cost- effective on a system-wide basis, largely due to more efficient coverage of large geographic areas, reduced patient transport times, and more rapid intervention that can reduce overall patient care costs.17 In general, air ambulance services have garnered wide community support and endorsement from the medical community as being a beneficial and cost-effective service for improving access to critical health care and increasing the chances of survival and recovery for trauma victims and critically ill patients, particularly in areas where access to specialized health care is limited. Consequently, air ambulance utilization is likely to continue its steady growth throughout the United States, particularly in rural areas. This expectation of continued growth for the industry draws particular attention to the ongoing safety concerns, because continued growth without any improvement to safety could trigger widespread public concern over the safety of these operations which has already been evidenced to some degree based on recent media coverage of the issue.18 State of the Air Ambulance Industry The civilian air ambulance industry can trace its origins back to the early 1970s with the creation of the Maryland State Police aviation program in 1970 and the first hospital-based medical helicopter service at St. Anthony’s Hospital in Denver, Colorado in 1972. Prior to then, police departments in the 1960s and early 1970s had 14 Ibid. Note: Unlike other helicopters and aircraft used in search and rescue (SAR) and relief missions during natural disasters, dedicated air ambulances are specially equipped and staffed for transporting sick and injured patients. This report only discusses safety data and issues for dedicated air ambulance aircraft. 15 Barry Meier. “Crashes Start Debate on Safety of Sky Ambulances.” The New York Times, February 28, 2005. 16 Foundation for Air-Medical Research & Education (FARE), Air Medicine. 17 Ibid. 18 See especially Barry Meier. “Crashes Start Debate on Safety of Sky Ambulances” and Alan Levin and Robert Davis, “Surge in Crashes Scars Air Ambulance Industry.” CRS-7 used helicopters on occasion to transport critical patients, but provided very limited en route patient care. The air ambulance industry gradually grew during the 1970s and by 1980 included 32 helicopter emergency services flying 39 helicopters. During the 1980s, the industry grew fivefold and by 1990 included 174 helicopter emergency services and 231 helicopters. The industry experienced continued growth in the 1990s expanding to 231 helicopter emergency services flying 400 helicopters by 2000.19 A variety of factors, including increases in Medicare reimbursement rates for air ambulance services and recent declines in available emergency medical and advanced patient care services in rural areas, have resulted in a significant growth in the air ambulance industry over the past five years. In 2005, there were 272 helicopter emergency services flying 753 helicopters in the United States, roughly an 88% increase in the number of helicopter air ambulances compared to the size of the industry in 2000. In 2005, there were also an estimated 150 fixed-wing airplanes dedicated to air ambulance operations used mostly for inter-hospital transfers.20 Based on industry flight hour estimates, growth in the use of air ambulances has been increasing at a rate of about 4.5% per year over the past 15 years, and most observers believe that this steady growth in both the size of the dedicated air ambulance fleet in the United States and the utilization of air ambulances will continue over the next several years. While some states and municipalities and other public agencies operate air ambulances as public aircraft, most air ambulance services are privately owned and operated, either directly by a hospital or hospital consortium or by private aviation medical service providers. The Maryland State Highway Patrol has a comprehensive helicopter air ambulance capability that covers the entire state, while the California Highway Patrol and the Virginia and Delaware State Police provide air ambulance services in portions of those states. Several county police forces and emergency medical units throughout the United States also perform air ambulance missions. Also, federally operated aircraft provided by the U.S. Coast Guard in Alaska and the U.S. Army in Hawaii conduct civilian air ambulance operations. CRS estimates that federal, state, and local government-operated aircraft currently account for about 10% of air ambulance operations in the United States. However, private operators make up the large majority of air ambulance services across the United States.21 Unlike aircraft that are operated by a state or local agency which are considered public aircraft and therefore not under direct FAA oversight, air ambulances operated by private companies are regulated by the FAA, and therefore have been the focus of safety studies examining safety within the industry and the FAA’s actions to monitor and regulate safety.22 These private aviation medical providers may operate under 19 Foundation for Air-Medical Research & Education (FARE), Air Medicine. 20 Ibid. 21 See the Association of Air Medical Services (AAMS), Atlas & Database of Air Medical Services (ADAMS). AAMS National Office, Alexandria, VA for a comprehensive geographic database of air ambulance service coverage across the United States. 22 CRS is not aware of any study examining the safety of public aircraft used as air (continued...)
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